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Publication of “Swap” Definition Triggers Dodd-Frank Derivatives Reform Compliance Dates

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The joint final rules adopted last month by the Commodity Futures Trading Commission (CFTC) and the Securities and Exchange Commission (SEC) to further define the terms “swap” and “security-based swap” were published in the Federal Register today. The joint final rules, which were adopted by the CFTC on July 10, will become effective on October 12, 2012. These rules are a key component of the new regulatory regime imposed on the over-the-counter derivatives market by the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act).

Publication of the joint final rules in the Federal Register triggers the compliance dates for a number of CFTC final rules. The chart below identifies the compliance dates for several of the key final rules that the CFTC has issued to date to implement Title VII of the Dodd-Frank Act that are triggered by the publication of the joint final rules in the Federal Register. Market participants should be prepared to comply with the relevant Dodd-Frank Act requirements as of the dates listed below.

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Published In: Administrative Law Updates, Business Organization Updates, Finance & Banking Updates, Securities Law Updates

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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